G.R. No. 189311 - Manzanal vs. Ilusorio

On July 7, 1994, a penthouse unit (PH-1) at the Baguio Country Club Corporation (BCCC) building was assigned to respondent Ramon K. Ilusorio by Felix Adolfo B. Lopez, Jr., with the consent of BCCC.
For a period of five years following the assignment, respondent enjoyed the use of the unit and the club’s facilities along with his business colleagues and friends.
In 1998, a family conflict arose, leading to respondent being barred from the unit and nearly expelled as a club member, which set in motion a series of legal actions.

On May 31, 2001, respondent requested his current statement of account from BCCC.
BCCC initially charged him the amount of P102,076.74, which he paid under protest.
A subsequent letter dated November 26, 2001 provided a detailed breakdown, indicating a total amount due of P2,928,223.26; this included:

Guest room charges from April 1995 to July 1999 amounting to P2,431,000.00 for an estimated ninety-seven guests, predominantly Multinational Investment Bancorporation partners and personnel.
Additional charges for rectification works amounting to P599,300.00, supposedly related to alleged encroachments.

A final demand letter dated December 19, 2001 called for prompt payment, warning of possible further action under the club’s rules.

The authority of Dennis R. Manzanal as the Assistant Vice President of BCCC.
The basis for billing amounts including charges from as far back as 1995 and the rectification works.

Respondent alleged that the demand letters were a tactic to harass him, using his family feud as a pretext to pressure him into payment.
In response, in 2002, respondent filed a complaint for damages before the Makati Regional Trial Court (RTC), asserting two causes of action:

The claim that the charging and collection of P2,928,223.26 were baseless, harassing, and without proper legal or factual foundation.
The assertion that these acts resulted in moral damages, including mental anguish and social humiliation.

The act of sending a demand letter does not itself constitute a cause of action.
As an officer acting on behalf of BCCC, he should not be personally liable.

BCCC also sought dismissal on the ground of litis pendentia, noting that a related collection suit was pending in the RTC of Baguio City (Civil Case No. 4750-R).
The RTC of Makati City, Branch 145, dismissed the complaint on October 10, 2002, ruling that basing a cause of action merely on the sending of a demand letter was not sufficient.
The Court of Appeals, in a decision dated November 26, 2008, reversed the RTC decision and reinstated the complaint.
Petitioners subsequently sought review, and the case reached the Supreme Court, which granted the petition for review.

Whether the complaint for damages filed by respondent states a valid cause of action.

Does the mere issuance of demand letters, as executed by BCCC and Manzanal, constitute an actionable wrong?
Is the billing for charges, especially those dating back to 1995, legally and factually sustainable?
Can the actions of petitioners be deemed abusive or harassing, thereby giving rise to compensable damages under the complaint?